The report, published on November 16, outlines a number of recommendations for robust new measures, including a ban on the third party sale of puppies and the suggestion that the RSPCA shouldn’t carry out animal welfare prosecutions. Whilst PIF welcomes the suggestion for animal welfare prosecutions to go through the Crown Prosecution Service (CPS), it would want to ensure that the CPS placed a high priority on such cases so that animal welfare wasn’t compromised.

Nigel Baker, chief executive, said: “Whilst many of the committee’s recommendations are to be applauded, some, in particular the proposal to ban the third party sale of puppies, could lead to unforeseen consequences. PIF would have no problem with third party sales of puppies being banned per se, provided that doing so doesn’t result in further welfare concerns arising as a result of a ban.

“However, the reality is that the demand for puppies (estimated at about 800,000 per year) clearly outstrips the supply. PIF is therefore concerned that puppy sales could be forced underground and the opportunity to put regulation and enforcement into these vendors to ensure that the welfare of the animals remains paramount would be removed.

“In the USA, 30% of puppies are now acquired through unlicensed and unregulated rehoming centres as a result of certain states banning third party sales of puppies, and whilst the committee suggests ‘approved rehoming’ centres are a possible source of puppies, it is important to remember that in the UK re-homing centres are also currently unlicensed. Such a move begs the question – is it right to move puppy sales from a licensed premises to an unlicensed premises?

“As an alternative to banning third party sales, PIF would suggest that the guidelines and the criteria used when licensing the third party sale of puppies is made far more robust, with puppy welfare rather than commercial considerations at their core”.

Nigel continued: “PIF is also concerned that the recommendation to ban third party puppy sales has been made without the committee completely understanding the picture of the puppy market in the UK today. The report quotes some wildly differing statistics for the size of the puppy market (cited as between 700,000 and 1.7m puppies) and if a ban were to be implemented today, it would only actually affect 80 premises (i.e. those currently licensed to sell puppies; split between 30 retail premises and 50 private dwellings).

“PIF would prefer to see recommendations made on concrete data so that the scale of the issue is fully understood. The risk is that basing a ban on uncertain data might not have the impact that it is intended to have, because sadly large parts of the puppy trade are already likely to be underground.”